A federal appeals court ruling that invalidated President Obama’s recess appointments to the National Labor Relations Board is also calling into question not only a similar recess appointment of the director of the Consumer Financial Protection Bureau, but also everything the CFPB has done under his watch.

“There is a question of what the CFPB has done in the past versus what it will do in the future. There’s a certain authority without a director,” said Christopher J. Willis, an Atlanta-based partner in Ballard Spahr’s Consumer Financial Services Group.

But the extent of the CFPB’s authority is unknown. If a court overturns the director’s appointment, it could call into question an entire year of CFPB rulemaking, which includes more than a dozen mortgage-related issues.

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Consumer Financial Services